Sustainability-Related Disclosures
Website Disclosure in Accordance with SFDR Article 10(1) for an Article 8 Fund
Last updated: 28 March 2025
a) Summary
Resscapital AB (“Ress Capital”, the “Fund Manager”), as the manager of the fund Ress Life Investments A/S (the “Fund”), is subject to the transparency requirements of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR”). The Fund is classified under Article 8 of the SFDR, meaning it promotes environmental and/or social characteristics but does not have sustainable investment as its objective.
This disclosure outlines how the Fund promotes social characteristics in accordance with the disclosure requirements of Article 10(1) of the SFDR.
b) No sustainable investment objective
This financial product promotes social characteristics but does not have sustainable investment as its objective or promote environmental characteristics.
Investments in life insurance policies, also known as life settlements, are considered to have no material environmental impact, as transactions only result in a change of contracting parties. Accordingly, the Fund does not promote environmental characteristics. The Fund’s investments are considered not to cause significant harm to any environmental or social objectives.
c) Environmental or social characteristics of the financial product
The Fund promotes social characteristics by purchasing life insurance policies from individuals who no longer need coverage or can no longer afford premium payments. The transaction enables elderly policyholders to receive a cash payout for policies that might otherwise lapse due to non-payment of premiums. While these investments have no direct environmental footprint, they are intended to support social benefits by improving the financial security and welfare of senior individuals in the US.
The Fund promotes social characteristics through two investment strategies: (i) Exclusion and (ii) Impact. These are described in more detail in section d) Investment strategy.
d) Investment strategy
The overarching philosophy of the Fund’s investment strategy is to invest in US life insurance policies in the secondary market. The objective is to build a balanced portfolio that delivers attractive, uncorrelated returns over time while acting in a sustainable manner and promoting social characteristics.
To promote these characteristics, the Fund applies two investment strategies:
(i) Exclusion: The Fund applies a norms-based screening process to avoid investments in life insurance companies involved in violations of internationally recognised norms and standards, including, at a minimum, the UN Global Compact and OECD Guidelines for Multinational Enterprises (e.g. related to human rights, labour standards, and anti-corruption). As part of this process, sustainability-related risks, as defined in Article 2(22) of Regulation (EU) 2019/2088 (SFDR), are considered. These refer to environmental, social, or governance events or conditions that, if they occur, could cause a material negative impact on the value of an investment. The Fund uses third-party ESG data to identify such sustainability-related risks.
(ii) Impact: The Fund Manager collaborates with counterparties, e.g. intermediaries and service providers, that support improved transparency, ethical practices, and consumer protection in the life settlement market. The Fund Manager only invests through counterparties who are registered and authorised according to the state legislation in the state where the transaction takes place. This approach supports high standards of conduct and fosters long-term positive social outcomes for policyholders and beneficiaries.
In the context of life settlements, ethics is a key aspect of social sustainability. The Fund manager places emphasis on transparency, open dialogue, and professionalism in its relationships. Complaints procedures and investor support should be efficient, thorough, and handled with professionalism. Further, the secondary market for US life insurance policies is regulated in most US states. The legislation regulating the market is there to safeguard the individual policyholder’s, i.e. the consumer’s interest. The legislation aims to protect the consumer’s freedom of choice and ensure that the sales process is transparent and correct. Brokerage fees must be disclosed in a clear and transparent manner to the consumer.
The Fund Manager is active in promoting and supporting investor initiatives aiming at improving the consumers’ rights when selling their life insurance policies. To enable the individual household to make an informed decision, it is important that the sales process is transparent. The Fund Manager is an active member of the trade organisations ILMA (Institutional Longevity Markets Association) and ELSA (European Life Settlement Association), which support such initiatives.
Good governance practices
While the Fund does not invest directly in life insurance companies via equity or debt instruments, the issuers of the life insurance policies acquired in the secondary market are subject to the norms-based screening to ensure alignment with international standards for good governance. In addition, the Fund promotes good governance by requiring that our counterparties act ethically, comply with applicable regulations, and maintain high standards of transparency throughout the sales process.
e) Proportion of investments in ESG and non-ESG assets
#1 Aligned with E/S characteristics includes the investments of the financial product used to attain the environmental or social characteristics promoted by the financial product.
#2 Other includes the remaining investments of the financial product which are neither aligned with the environmental or social characteristics, nor are qualified as sustainable investments.
The category #1 Aligned with E/S characteristics covers:
– The sub-category #1A Sustainable covers sustainable investments with environmental or social objectives.
– The sub-category #1B Other E/S characteristics covers investments aligned with the environmental or social characteristics that do not qualify as sustainable investments.
The Fund holds three types of assets:
(i) US life insurance policies
(ii) US Treasury bills
(iii) Cash deposited with US and European Union banks
The Fund Manager expects approximately 90% of the Fund’s assets to consist of US life insurance policies, which are intended to promote social characteristics in line with the Fund’s investment strategy. These are categorised as #1 Aligned with E/S characteristics, and more specifically under #1B Other E/S characteristics. The Fund does not make sustainable investments as defined in Article 2(17) of SFDR, and therefore the share of #1A Sustainable investments is 0%.
The remaining portion, approximately 10%, falls within the category “#2 Other”. This includes cash deposits and Treasury bills held for liquidity management purposes, which are not assessed against the Fund’s promoted social characteristics and are not subject to any minimum safeguards.
The Fund does not consider the EU Taxonomy, as set out in Regulation (EU) 2020/852, in its investment strategy, as the asset class is currently not covered by the scope of the framework. Accordingly, the proportion of taxonomy-aligned investments is 0%, and the Fund does not commit to a minimum share of investments in transitional and enabling activities.
f) Monitoring of environmental or social characteristics
The promoted social characteristics are monitored regularly throughout the lifecycle of the Fund. The Fund collects third-party ESG data to screen potential sustainability-related risks among life insurance companies. These reviews focus on identifying any involvement in significant ESG-related controversies, such as breaches of international norms, human rights violations, or governance-related incidents.
These sustainability-related risks are integrated into the Fund’s pre-investment due diligence and monitored on a quarterly basis through portfolio reviews and internal ESG reports prepared by the portfolio management team. In addition to data-driven monitoring, the Fund conducts qualitative assessments of counterparties both prior to investment and on an ongoing basis.
The Fund’s investment convictions may be adjusted over time based on insights from both quantitative ESG data and qualitative assessments.
g) Methodologies
The Fund Manager is responsible for the methodologies used to measure the attainment of the Fund’s promoted social characteristics, which is measured through a combination of quantitative data from an independent ESG data provider and internal qualitative assessments carried out by the portfolio management team. The following indicators are used to measure the extent to which the Fund’s investments promote social characteristics:
- Percentage of life insurance companies that contribute to social cohesion
- Percentage of life insurance companies that do not contribute to social cohesion
- Percentage of life insurance companies that follow international norms and conventions
- Percentage of life insurance companies that violate international norms and conventions
h) Data sources and processing
I. The data sources used to achieve each of the environmental or social characteristics promoted by the financial product
The Fund Manager strives to measure the attainment of social characteristics using a variety of data sources. The Fund Manager accesses data via an independent third-party ESG data platform and other available sources. The ESG data cover risk ratings, norm-based screening, and assessments of compliance with international frameworks such as the UN Global Compact and OECD Guidelines.
II. The measures taken to ensure data quality
The third-party ESG data provider is selected based on the width of its coverage and the perceived quality and reliability of its methodology. The provider applies a standardised methodology that combines data-driven and judgement-based inputs, supported by internal quality controls, peer benchmarking, and data validation procedures to ensure consistency and comparability of indicators. The Fund Manager conducts regular reviews of the quality of data sources.
III. How data are processed
ESG data is integrated into the Fund’s pre-investment due diligence and ongoing monitoring. The data is processed internally by the portfolio management team. It is used to evaluate compliance with exclusion criteria, monitor social characteristics, and identify potential ESG-related risks or opportunities.
IV. The proportion of data that are estimated
A significant portion of the ESG data used by the Fund consists of estimates provided by the third-party ESG data provider. Due to gaps in corporate disclosures and varying data availability, the proportion of estimated data varies by dataset and is dependent on the provider’s coverage.
i) Limitations to methodologies and data
The Fund Manager relies, to a large extent, on models and estimates provided by the third-party ESG data provider. Measuring sustainability indicators can be challenging due to incomplete or inadequate information. Limitations in data coverage, consistency, and quality may affect the accuracy of some of the assessments. While data limitations exist, the Fund Manager strives to ensure a comprehensive process by combining third-party insights with internal judgement and regular monitoring.
j) Due diligence
The Fund Manager conducts due diligence on the underlying life insurance policies with a focus on sustainability-related risks. This includes the use of third-party ESG research and data to screen out life insurance companies involved in severe controversies or breaches of international norms.
Prior to acquiring a policy, the ESG profile of the issuing insurance company is assessed, including governance practices and exposure to sustainability-related risks. These factors are considered alongside the traditional financial analysis during the investment decision-making process.
ESG risks are also monitored throughout the holding period and are reflected in internal reports and risk assessments, helping to inform portfolio-level risk management and exclusion decisions.
k) Engagement policies
The Fund does not invest in equities or corporate debt instruments and therefore does not exercise active ownership through voting rights or direct engagement with life insurance companies on ESG matters. As such, the Fund is not in a position to influence governance decisions through general meetings or board nominations. Instead, the Fund Manager engages with intermediaries and other stakeholders in the life settlement market as part of its broader commitment to promoting social characteristics.
l) Designated reference benchmark
No index has been designated as a reference benchmark to meet the social characteristics promoted by the financial product.
